SIZEWELL C STAGE 4 PRE-APPLICATION CONSULTATION
Representations from Leiston-cum-Sizewell Town Council
Leiston-cum-Sizewell Town Council stands by their Stage 3 representation which includes Leiston residents four main concerns:
· The intense pressure on the Town by virtue of the sheer scale and numbers inherent in all aspects of the construction
· Traffic through the town and around the wider highways network
· Loss of Public Rights of Way and access to the beach
· Homes in Multiple Occupation and fly parking in the town causing nuisance, a major loss of amenity and additional congestion in already narrow streets
The Town Council ask that EDF Energy continue to respond to and
address the issues contained in that submission. Leiston has undoubtedly benefitted
from having both Sizewell A and, more so, SZB as our neighbours but only once
they had reached their operational stage. It is expected that SZC would have a
similar socio-economic impact once completely operational but, currently,
it remains the Town Council’s belief that the benefits of the project throughout
construction are outweighed by the above negative social and environmental
impacts. Serious mitigation through the first 15 years will be needed to
ensure that the long term benefits are realised. The more specific measures
needed are included (again) in Annex B.
In respect of the latest consultation (Stage 4) the Town Council’s additional comments are as follows
The main platform
The introduction of the pylons and a further incursion into the SSSI highlight and reinforce our previously expressed concerns regarding the size and suitability of the site. The tight boundaries within which EDF Energy intend to operate must be acknowledged by the Inspectorate and it must be documented that any further applications for extensions to the platform site for unforeseen purposes, if a DCO is granted, will not be allowed. The Town Council would therefore, reluctantly, support the five pylon option (2) as every effort has to be made to protect the visual aesthetics of the AONB.
The workforce
Leiston Town Council note that the 7,900 - 8,500 workers peak is no longer for sensitivity testing but is likely to be the maximum. This obviously exacerbates our concerns regarding HMO’s and other residential/accommodation issues that we highlighted at Stage 3. The accommodation block will need more capacity for the anticipated peak workforce to avoid further impact on traffic, fly parking and all the other associated issues in and immediately around Leiston. If the 2,400 capacity of the campus is not to be increased EDF need to give some indication of how or where they anticipate the other 5,000 - 6,000 workers will be domiciled. Even taking into account the local workforce there will be intense pressure on Leiston for accommodation, services and leisure. The 3G pitch at Alde Valley Academy is welcomed but the Town Council would wish to see facilities in the west of the Town enhanced too for residents’ use. For the construction period it is hoped that the workforce takes advantage of the Leisure facilities available in Red House Lane but this will obviously make it difficult for residents to enjoy the easy access they currently have to their leisure facilities. The Waterloo Centre in the west of the town, recently acquired by the Town Council, has huge potential to provide leisure and social cohesion to residents who wish to try and carry on with a normal life amongst the upheaval that a doubling of our population in the parish will bring. The town has a clear vision on how this centre should develop and would welcome EDF Energy’s support in achieving this aim. It would need a substantial investment (in Town Council terms) to make the changes needed but there is a project already developed to achieve this which, with a relatively small investment from EDF Energy, could be accomplished and enjoyed by all, helping to offset the upheaval.
With regard to HMO’s it would be good to reach an understanding with EDF Energy on how the off site accommodation is going to be managed whether this be by register or by other administrative means.
Transport
EDF Energy have given further predictions for a new
“integrated” transport strategy in Stage 4 whilst still keeping the Road Led
and Rail Led options in the paperwork. Proposals to enhance roads and mitigate
transport impacts on more distant communities are noted and welcome. However none
address our concerns from Stage 3 about the cumulative effects on Leiston. This
is particularly pertinent in the light of the “comprehensive urban plan for
Leiston town centre in accordance with the Leiston Neighbourhood Plan” that is
being pursued as this is a significant element of the current “Destination
Leiston” activity. This activity aims to secure and improve Leiston’s economic
health, increase footfall and dwell time, enhance the urban environment as well
as updating the library and other civic offices. A perception of safe pedestrian movement is absolutely
central to its success while still encouraging visitors travelling by car. The
Town Council is very grateful to EDF Energy for sharing information about the
emerging projected traffic flows at a recent meeting (3/9/19). The offer to
hold a further meeting with the Town Council, specifically on traffic, and
without the pressure of a full council agenda was gratefully received. It is
felt that the meeting should also involve representatives from Suffolk Highways
and Leiston Together. There are a number of specific points from the
presentation made on 3/9/19 that require further clarification to ensure that
appropriate mitigation can be made. In particular there is a concern about the
junction of the B1069 and the B1119. The presentation suggested that this
junction is likely to be operating at full capacity in the reference case scenario,
without any additional traffic related to SZC. It is unclear how the 'increased
efficiency of the existing traffic lights' suggested, will be sufficient to
alleviate the pressure on this junction. The Town Council would welcome the
advice of Suffolk Highways to clarify what further mitigation could be made,
either to improve this junction, or to divert traffic away from it. Another
option that we would like to explore with you is the possible relevance, or
not, of the extensive 2002 traffic study into the town centre and whether there
is a still a case for a one-way system. The results of this study are at Annex
A to this response for your interest and examination. Other ideas, such as
shared space, should also be explored as well as the group going on to produce
and agree a clear signage proposal for the town and the various local routes
associated with the Sizewell C development. EDF Energy must do a comprehensive and
up to date study of the reference case and the predicted traffic flows through
the town and along the major routes into and out of the town. This should
include options for mitigation and traffic control measures to ensure the
increase in movements is managed properly. It should also take advantage of any
local knowledge gathered from the meeting(s) offered above and begin to look at
specific mitigations. It is therefore requested that EDF Energy join with the Town Council, Suffolk Highways
and Leiston Together to discuss this and to begin the work needed to accompany
the DCO.
It is noted and welcomed that in the rail and integrated strategy the two initial train loads each day would still be stabled outside Saxmundham before moving into LEEIE after 7am. This consultation also states that the frequency of freight (by rail) would not increase until the Green Route has been constructed. This is also welcomed. The Town Council would re-iterate that, for the Green Rail Route, that Buckleswood Road must have an automated crossing and the footpath (No. 3) from Fishers Farm should have an appropriate off road stretch constructed from where it meets Buckleswood Road to the rail crossing to allow it to then join the realigned section to the east of the green route.
Not obvious from the consultation but it is believed that it is EDF Energy’s intention to upgrade the rails through the town to supress the rolling noise. It is requested that this also addresses the long-standing depression across the road at the Station Road crossing. The rail level there needs to be graded up a small amount to make transit across the rail bed more comfortable.
The LEEIE options are noted and the extended rail spur (Option 3) into the site would seem the most appropriate to allow for long trains. The level crossing in King Georges Avenue servicing the rail head should never be needed with this solution. The other option of enhancing the existing line alongside the LEEIE (Option 2) may well inhibit the length of train or require the level crossing to be used. Option 1 is a complete non-starter as a permanent solution. Even should the spur not be constructed in time this must not be considered other than as a time-limited, very temporary solution during the spur’s construction. Should this be unavoidable, the train lengths must be managed to ensure the train fits fully into the railhead. The King Georges Avenue rail crossing must be automated too.
The LEEIE
The layout of the LEEIE needs to be designed such that the park and ride and all other HGV and caravan park traffic egresses onto Lovers Lane. It could be that, with the proposed flood alleviation project in Sandy Lane (see later), a substantial signalled crossroads will be necessary and should be installed in the vicinity of the Valley Road/Sandy lane junction. This would be necessary for safe ingress and egress for all users of the LEEIE. There should be no access onto King Georges Avenue but, if this remains, then a roundabout needs to be installed at the Crown Farm junction as moves into and out of this junction, with the volume of traffic, will be hazardous and difficult.
There is concern about the impact on Sandy Lane from the proposal to remove 9,000 cubic metres of soil from the Keepers Cottage Flood Compensation Area and take it to the LEEIE. It is imperative that Sandy Lane be strictly managed to only allow one HGV at one time to use the track (common ground) and for no additional passing places or widening to take place so that it retains its character throughout and after completion of the works.
The increase in tonnage and use of various key roads in
Leiston will degrade the road surfaces and therefore increase noise nuisance to
nearby properties. If the DCO is granted then there should be an immediate
undertaking to resurface the following roads with a resilient and noise
reducing surface in readiness for the onslaught. Sizewell Gap Road, Abbey Road,
Haylings Road (through to west Knodishall) and Waterloo Avenue.
Infrastructure
Leiston Town Council supports the construction of the Link Road, whatever strategy is decided upon, and consider that this should be built to adoptable highway standards and clearly be retained after the construction phase for future use by the power stations and local residents alike. This applies to all other highway infrastructure put in too. The roundabouts at Friday Street and Yoxford are long overdue and should be retained as should the Farnham bypass. They are broadly supportive too of the increase from 30mph to 40mph on the entrance roundabout to the site (on the B1122). This assists local traffic flow and the land take does not encroach further on Leiston Abbey although residents have expressed concern about further loss of trees and agricultural land. Further mitigation will be required at Pro Corda (Leiston Abbey) however to enhance the sound proofing and other facilities to combat the new train noise the Green Rail Route will bring to their environment.
As with the initial need to use the Leiston railhead, it is recognised that some works traffic will need to use the Sizewell Gap Road and current SZB site entrance at the start of the project. This should be a time-limited and very temporary solution as neither has the capacity to service any meaningful commencement of earthworks on the SZC site. Should this initial use be unavoidable it is considered necessary for EDF Energy to extend the new off road route (Bridleway 19 and Coastal Path alternative) along Sizewell Gap Road from the proposed heliport entrance to the SZB Site entrance thereby enhancing and strengthening the existing cycle path alongside that road. Even without this there needs to be a signalled crossing at the proposed heliport entrance otherwise users of the bridleway have no visibility of traffic from the west on a fast moving road (and nowhere to go on that side of the road – they have to cross) – this needs to be assessed by the Suffolk Highways safety team. A pelican crossing there and the construction and continuation of that route along the southern side of the hedge line going to Sizewell along Sizewell Gap Road would benefit residents, visitors and SZB workers greatly as a road safety measure and a legacy amenity.
There still needs to be a crossing of some kind to allow pedestrian access to the Kenton Hills Walks from the replacement bridleway (19) on the west side of Lovers Lane to cross to the east somewhere below the Observatory corner. This may have to lead onto a metalled footway alongside the Highway (on highway land) if the field to the east is unobtainable.
Overall
Given all the above, the overriding concern of the Town Council and residents is that all associated enabling infrastructure construction – Link Road, Green Route, LEEIE rail spur and the causeway are all completed before work starts on the main platform. This is imperative, because, even with the planned infrastructure improvements, pressure on existing routes will become excessive. To help allay fears that they may not, it would be appreciated if EDF Energy would publish a clear, simplified timeline on what associated development will be constructed, and when, alongside the onsite earthworks schedule. Leiston Town Council needs to see that there is a clear timeline for completion of the essential supporting infrastructure for this project which is realistic, workable and integrated with normal life and the other threatened energy projects in the parish.
Mitigation
As this project moves toward the DCO this is the final chance Leiston will get to request appropriate mitigation.
To be absolutely clear, with some 90% of the construction taking place in the Parish and a very large majority of the workforce living and taking recreation in the Town, Leiston-cum-Sizewell is asking for significant mitigation and support from EDF Energy to manage the pressure and the substantial reduction in amenity residents will have to endure. Leiston is currently working to achieve its vision of improving on its residential amenity and tourist appeal and this will severely hinder that quest. The Town Council would hope that the Principal Authorities would also recognise this and support ongoing talks with EDF Energy to help mitigate for this. There will inevitably be an extensive and significantly disruptive period which could last for years and the Town Council would like to engage with all authorities on the lead up to the DCO, including the Suffolk Community Foundation, to agree a package that would address the strain and burden envisaged from the outset of construction. This does not even address the additional concern of the windfarm programme.
The Council will support all comments from Suffolk Wildlife and the RSPB regarding the new compensation land proposals.
Annex A 2002 Suffolk County Council study into a one-way system in Leiston Town Centre commissioned to address pedestrian constraints in the town.
Annex B Long term and immediate mitigation requirements
Annex C Specific mitigation proposals for Leiston Town Centre
Annex D Comments and concerns raised by residents at a public meeting held 10 September 2019.
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